Advance tax ruling: Difference between revisions
imported>Doug Williamson (Add abbreviation 'ATR'. Source: Merlyn International Tax solutions: http://www.merlyn.eu/merlyn.asp?p=35) |
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(ATR). | (ATR). | ||
An advance tax ruling is a written confirmation by a tax authority of its interpretation of the tax law applying to a proposed transaction. | Advance tax rulings are sometimes also known as 'tax clearance', 'pre-clearance', 'non-statutory business clearance' or 'clearance'. | ||
They are designed to enable the parties to a proposed transaction to obtain reassurance (before committing to the transaction) about its tax effects. | |||
An advance tax ruling or clearance is a written confirmation by a tax authority of its interpretation of the tax law applying to a proposed transaction. | |||
In relation to major transactions, the parties may make the obtaining of a favourable advance tax ruling a precondition to completing the transaction. | In relation to major transactions, the parties may make the obtaining of a favourable advance tax ruling a precondition to completing the transaction. | ||
The detailed process and its legal effects differ, depending on the tax jurisdiction and the nature of the transaction. | |||
In all cases, the taxpayer must of course make full disclosure to the tax authority of all relevant information. | |||
== See also == | == See also == | ||
*[[ | *[[Base erosion and profit shifting]] | ||
*[[Clearance]] | |||
*[[Tax ruling]] | *[[Tax ruling]] | ||
*[[Tax transparency initiative]] | *[[Tax transparency initiative]] | ||
*[[ | *[[Transfer pricing]] | ||
[[Category:Accounting,_tax_and_regulation]] | |||
Latest revision as of 08:58, 16 November 2023
(ATR).
Advance tax rulings are sometimes also known as 'tax clearance', 'pre-clearance', 'non-statutory business clearance' or 'clearance'.
They are designed to enable the parties to a proposed transaction to obtain reassurance (before committing to the transaction) about its tax effects.
An advance tax ruling or clearance is a written confirmation by a tax authority of its interpretation of the tax law applying to a proposed transaction.
In relation to major transactions, the parties may make the obtaining of a favourable advance tax ruling a precondition to completing the transaction.
The detailed process and its legal effects differ, depending on the tax jurisdiction and the nature of the transaction.
In all cases, the taxpayer must of course make full disclosure to the tax authority of all relevant information.
